Code of Ethics

Code of Ethics and Academic Integrity Policy

Standard 4 – Integrity, accountability and information management

The Mediterranean Academy of Culture, Technology and Trade (MACTT) adopts this Code of Ethics and Academic Integrity Policy as the principal public statement of the values and conduct standards that govern its institutional, academic and administrative activity. The Code protects academic freedom while defining the responsibilities that accompany participation in a higher-education environment. It is intended to guide decisions, prevent avoidable misconduct, provide a clear route for concerns and support a culture in which evidence, fairness and accountability are treated as ordinary institutional disciplines.

The Code is proportionate to MACTT’s scale and relaunch phase. Proportionality does not reduce the applicable standard. It means that the Academy uses a clear allocation of responsibility, a limited number of controlled records and prompt escalation where needed instead of creating unnecessary committees or overlapping policies. The Code must be read together with the Information Management, Data Protection and Digital Records Procedure and with the authoritative governance, quality-management, learner-administration and GestWave VLE records maintained under the relevant Standards.

The existence of this policy demonstrates the approved ethical framework. It does not, by itself, demonstrate that every briefing, acknowledgement, declaration, case review or public outcome has already occurred. Implementation is evidenced through retrievable source records generated at the applicable trigger. Where an activity has not yet occurred, MACTT records that position accurately rather than treating a template as a completed activity.

This Code applies to the CEO / Legal Representative, the Head of Institute, the QA Officer, governance and academic contributors, Admissions and Registry, Student Support, Legal Policy and Privacy, the Marketing Office, the Head of Online Learning, the Head of IT & VLE, lecturers, tutors, assessors, learners, visiting contributors, consultants and service providers where their activity may affect MACTT. It applies to face-to-face, online, blended and project-based activity.

The Code applies to governance decisions, administration, recruitment and appointment interfaces, admissions, teaching, learning, assessment, performance evaluation, learner support, complaints and appeals handling, public communication, information management, research-related activity and creative activity where applicable. It also applies to the use of institutional systems, digital content, recordings and data generated through GestWave VLE or another approved digital route.

External support does not transfer accountability away from MACTT. Where an external contributor or service provider supports an activity, the responsible institutional role remains accountable for the purpose of the engagement, the applicable conduct expectations, the evidence retained and any action required.

MACTT expects all persons covered by the Code to act honestly, fairly and responsibly. Decisions and communications must be capable of being explained from the evidence available. No person may alter, suppress or misrepresent an academic, administrative, quality-assurance or institutional record in order to create a misleading position.

Respect is required in teaching, assessment, administration, governance and digital interaction. MACTT does not tolerate discrimination, harassment, bullying, intimidation, retaliation or conduct that undermines the dignity or lawful rights of another person. A person who raises a concern in good faith must not be disadvantaged for doing so.

Confidential information must be used only for an authorised purpose. Personal data, assessment evidence, learner records, staff records, commercially sensitive information and regulatory material must be accessed, discussed, shared and retained in a manner appropriate to the role and purpose.

Public and internal communication must be accurate and non-misleading. MACTT must not describe a programme, qualification, approval, delivery route, partnership, learner outcome or institutional status more positively or more definitively than the source evidence permits.

MACTT recognises academic freedom as the ability to question, discuss, teach, learn and contribute to academic or professionally relevant debate within the scope of lawful institutional activity. Academic freedom supports critical thought and the responsible exchange of ideas. It is essential to credible higher education and must not be reduced to uncritical agreement with an established position.

Academic freedom is exercised together with professional responsibility. It does not authorise discrimination, harassment, defamatory conduct, academic dishonesty, misuse of confidential information, unauthorised representation of MACTT, disregard of accredited programme requirements or the presentation of unsupported claims as established fact.

Where an academic, professional or public-interest discussion involves contested issues, contributors are expected to distinguish evidence, interpretation and opinion. The Academy encourages reasoned disagreement while requiring a respectful learning environment.

MACTT is committed to fair treatment in admission, teaching, assessment, learner support, appointment, performance evaluation and administrative decision-making. Decisions must be based on relevant criteria and applied consistently. A person must not be treated less favourably on an unlawful or irrelevant basis.

Harassment includes unwanted conduct that violates a person’s dignity or creates an intimidating, hostile, degrading, humiliating or offensive environment. Bullying, repeated disparagement, intimidation, discriminatory remarks and retaliation are inconsistent with the Code whether they occur in person, in writing, during an online session or through a digital communication channel.

A concern involving fair treatment or harassment is handled sensitively and with appropriate confidentiality. The Academy preserves the evidence available, identifies any immediate protective step, routes the matter to the responsible role and escalates it where the seriousness or the persons involved require an alternative decision route.

MACTT is committed to fair treatment in admission, teaching, assessment, learner support, appointment, performance evaluation and administrative decision-making. Decisions must be based on relevant criteria and applied consistently. A person must not be treated less favourably on an unlawful or irrelevant basis.

Harassment includes unwanted conduct that violates a person’s dignity or creates an intimidating, hostile, degrading,

A conflict of interest exists where a personal, professional, financial or relational interest may affect, or may reasonably be perceived as affecting, impartial judgement. A conflict can arise even where no improper decision has been made. Declaring a conflict is a protective control for the individual and for MACTT; it is not an admission of misconduct.

Relevant decision areas include governance, admission, assessment, moderation, appointment, procurement, partnership activity, complaints, appeals, external-service oversight and any other matter where an undisclosed interest could weaken confidence in the decision.

A person must declare an actual, potential or reasonably perceived conflict before participating in the relevant decision, or as soon as the conflict becomes apparent. The responsible institutional role records the declaration and determines a proportionate response. The response may include disclosure, restricted participation, recusal, the appointment of an alternative reviewer or another mitigation suitable to the decision.

Conflict declarations are retained through the applicable controlled register. Where a conflict affects the Head of Institute, the QA Officer or another senior role, the matter is escalated to the CEO / Legal Representative or to an appropriate alternative route that preserves impartiality.

Academic integrity is a condition for credible learning outcomes and reliable assessment. MACTT requires learners and academic contributors to act honestly in the preparation, submission, evaluation and retention of academic work. The Academy treats prevention, clear communication and proportionate response as connected responsibilities.

Lecturers, tutors and assessors must communicate the applicable assessment expectations, use assessment instructions that reduce avoidable ambiguity and preserve relevant evidence where a concern arises. Learners must submit their own work, acknowledge sources, comply with the permitted collaboration route and seek clarification where the assessment instructions do not resolve a question.

A suspected breach is considered on the evidence available and in light of the seriousness, context and recurrence of the matter. The Academy does not treat an allegation as a concluded fact before review. It also does not disregard a credible concern merely because the cohort or activity is small.

Academic-integrity risk Working definition for MACTT
Plagiarism Presenting another person’s words, ideas, data, design, media or work as one’s own without appropriate acknowledgement.
Cheating Using unauthorised materials, assistance, devices, communication or methods during an assessment.
Collusion Unauthorised collaboration where individual work is required.
Contract cheating Submitting work produced, purchased or substantially prepared by another person or service.
Falsification Creating, altering or misrepresenting evidence, data, attendance, assessment submissions, certificates or institutional records.
Misuse of AI or digital tools Using a tool contrary to assessment instructions, without a required disclosure or in a way that prevents assessment of the learner’s own achievement.
Assessment interference Attempting to influence marking, moderation, records or academic decisions through improper means.

Generative AI and other digital tools may support learning where their use is compatible with the intended learning outcomes and the assessment instructions. Their use is not automatically prohibited and is not automatically permitted. The relevant assessment brief determines whether use is allowed, restricted or excluded and whether disclosure is required.

A learner must not use a tool in a way that conceals the origin of work, substitutes for the learner’s own achievement or defeats the purpose of the assessment. Where the instructions are silent or uncertain, the learner must seek clarification before relying on the tool for assessed work.

Lecturers and assessors should define expectations clearly and consider whether the assessment design remains capable of demonstrating the learner’s achievement. Where a concern arises, the Academy reviews the available evidence proportionately and avoids conclusions based solely on an unsupported assumption about tool use.

The same ethical expectations apply in GestWave VLE and in any approved digital environment. Users must protect their credentials, access only the information required for their role and report suspected unauthorised access or misuse. Credentials must not be shared. Institutional systems must not be used to upload unlawful, discriminatory, offensive or malicious content or to interfere with teaching, assessment, learner support or security.

An online lesson, tutorial, assessment meeting, learner-support meeting or governance meeting may be recorded only where there is an authorised educational, administrative, quality-assurance or compliance purpose and where the applicable notice, lawful basis, access control and retention decision have been addressed. Participants must not record, copy, download, distribute or publish a session without authorisation.

Teaching materials, recordings, assessment briefs, learner work and other creative outputs may contain intellectual property belonging to MACTT, learners, tutors, contributors, partners or third parties. Materials must not be copied, reused, published, sold or commercialised without permission or an applicable licence. Any intended public use of learner work requires the appropriate authorisation.

Digital tools may generate access, participation, submission, assessment and security traces. These data may be used for academic administration, learner support, quality review, integrity review and compliance where relevant. Use must remain limited to a defined purpose and comply with the Information Management, Data Protection and Digital Records Procedure.

The Code is intended to prevent avoidable problems as well as to guide responses. MACTT therefore communicates the applicable expectations through the route appropriate to the activity. Relevant staff, lecturers, tutors and assessors receive the Code or a controlled briefing route when they are onboarded or before the activity for which the rules are relevant.

Learners receive the applicable ethical, academic-integrity and digital-conduct expectations through induction, programme information, the student agreement or another controlled learner-information route before the relevant activity. Assessment-specific requirements, including any rule concerning collaboration, sources, AI or digital tools, must also appear in the assessment instructions where relevant.

A communication template or induction section demonstrates the approved route. Actual dissemination is demonstrated by the source evidence retained for the relevant cohort or contributor group. The QA Officer checks that the Academy does not report dissemination as complete merely because a template exists.

A learner, staff member, lecturer, tutor, assessor, institutional role, external contributor or partner may raise a concern. The concern is reported to the Head of Institute or QA Officer through an appropriate written or recorded route. Where the matter involves either of those roles, it is escalated to the CEO / Legal Representative or to an appropriate alternative route.

The receiving role records the source of the concern, identifies any immediate protective action and preserves the relevant evidence securely. Depending on the matter, the evidence may include submissions, messages, assessment records, access records, correspondence, screenshots, declarations or a concise dated note.

Confidentiality is protected according to need and purpose. Information is shared only with the roles needed to review, decide, implement or verify the response. Confidentiality does not prevent escalation where learner protection, regulatory compliance, legal obligations or the seriousness of the matter require action.

The Head of Institute coordinates the academic or operational response. The QA Officer maintains an objective evidence-control role, checks that the applicable record is complete and ensures that follow-up remains visible. The CEO / Legal Representative considers material institutional, regulatory, legal or reputational matters.

The review route is proportionate to the matter. A minor clarification may be resolved through a concise record. A concern affecting assessment integrity, fair treatment, privacy, public information, institutional records or a senior role requires a more formal review and a retrievable decision record.

Possible responses include clarification, guidance, a warning, resubmission where permitted, an assessment consequence, restricted access, referral to the applicable complaints or appeals route, corrective action, additional briefing, supplier follow-up or escalation to an external authority where legally required. The response must be consistent with the evidence, seriousness and recurrence of the matter.

An outcome is not treated as closed until the decision record and any required closure evidence can be retrieved. Where an action extends beyond the immediate outcome, the responsible role, trigger, expected output and QA verification route are retained in the applicable action log.

A concern under the Code may overlap with another institutional route. A complaint concerns a service or learner-experience issue. An academic appeal seeks review of an academic decision. A privacy or security concern may require an information-management response. A technical incident may require the GestWave VLE escalation route.

The substance of the matter determines the applicable route. Where more than one route is relevant, the records identify the relationship and preserve a coherent outcome. The Code does not replace the detailed complaints, appeals, privacy or technical procedures. It provides the ethical framework that informs their use.

MACTT retains records sufficient to demonstrate the operation of the Code. Depending on the trigger, these may include publication evidence, controlled communication evidence, learner acknowledgements, conflict-of-interest declarations, case records, evidence references, decision notes, corrective actions and proportionate outcome summaries.

A blank register is not evidence that no cases occurred. A nil return may be recorded only after a defined reporting period has elapsed and the responsible role has checked the applicable register or route. The entry identifies the period reviewed, the date of the check and the QA verification. A verified nil return demonstrates active monitoring for that period; it does not demonstrate that integrity risk is absent.

The QA Officer reviews the evidence position periodically and identifies missing attachments, overdue actions and material trends where comparable evidence exists. MACTT does not claim a historical trend or complete maturity before the supporting records permit that conclusion.

This Code is publicly available on the institutional website at https://www.mactt.eu/code-of-ethics/ The public URL is retained as the primary publication route and has been verified as reachable during the current QA review. The Marketing Office and Head of Institute ensure that the published version remains current and consistent with the controlled document.

MACTT also maintains a proportionate public-outcome route for the application of the Code. Where a summary is appropriate, it is reported in aggregate or anonymised form and is limited to information that can lawfully and responsibly be made public. The Academy does not disclose personal data, confidential case details or information that could unfairly identify an individual.

Where no reportable outcome exists for a verified period, the Academy may publish or retain an appropriate nil-return statement only after the applicable register check has occurred. Transparency is intended to show that the Code is an operating control without compromising confidentiality.

Responsibility is distributed according to institutional role. The table below is a navigation aid. It does not replace the narrative duties established throughout the Code or the more detailed responsibility routes controlled under the IQA Manual.

Institutional role Principal responsibility under this Code
CEO / Legal Representative Retains institutional accountability; considers material escalation, senior-role conflicts, legal or regulatory implications and significant reputational risk.
Head of Institute Owns implementation of the Code; coordinates academic and operational response; ensures that relevant roles understand the applicable route.
QA Officer Remains distinct from the Head of Institute; maintains evidence control, reviews register completeness, tracks follow-up and escalates unresolved gaps.
Admissions and Registry Supports learner-information, induction, acknowledgement and student-record routes where applicable.
Legal Policy and Privacy Supports lawful handling, privacy, learner-rights and confidentiality considerations.
Head of Online Learning Leads educational-readiness and staff-orientation considerations for online and blended activity.
Head of IT & VLE Leads access, security, technical evidence and incident-escalation considerations for GestWave VLE.
Lecturers, tutors and assessors Communicate expectations, apply assessment rules, preserve evidence and raise concerns promptly.
Learners Act honestly, respect others, comply with assessment and digital-conduct rules and raise concerns responsibly.
External contributors and service providers Comply with the Code where their activity affects MACTT and cooperate with the applicable evidence and escalation route.

The Code is reviewed annually and earlier following a material regulatory change, integrity concern, programme activation, assessment change, public-information issue or change affecting online or blended delivery. The review considers whether the policy remains suitable, whether the communication route is functioning, whether declarations and cases are recorded appropriately and whether any repeated issue requires a policy or procedural improvement.

Evidence is retained in the authoritative controlled location. Cross-standard records are referenced rather than copied where another Standard already controls the applicable document. This prevents duplication and reduces the risk of conflicting versions.

A revision identifies the reason for change, the affected control and the records or communications that must be updated. Superseded revisions remain available as historical background but are separated from the current controlled policy.

18. Documentary Approval

This Code is approved by institutional role for controlled use and public availability. Documentary approval is recorded without a separate execution form.

Institutional role Approval status Documentary approval date Control note
QA Officer Approved 10 January 2026 Controlled for evidence traceability and consistency with the Standard 4 route.
Head of Institute Approved 10 January 2026 Reviewed for academic and operational coherence.
CEO / Legal Representative Approved 10 January 2026 Approved for controlled institutional use and public availability.